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HomeMy WebLinkAboutAQ_F_0100010_20220615_CMPL_InspRpt (5) NORTH CAROLINA DIVISION OF Winston-Salem Regional Office AIR QUALITY Stericycle, Inc. NC Facility ID 0100010 Inspection Report County/FIPS:Alamance/001 Date: 06/15/2022 Facility Data Permit Data Stericycle, Inc. Permit 05896/T25 1168 Porter Avenue Issued 12/19/2016 Haw River,NC 27258 Expires 11/30/2021 Lat: 36d 3.9660m Long: 79d 20.9230m Class/Status Title V SIC: 4953/Refuse Systems Permit Status Active NAICS: 562213/Solid Waste Combustors and Incinerators Current Permit Application(s)TV-Renewal Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V Don Nuss Kirk Yarbrough Don Nuss MACT Part 63: Subpart ZZZZ Regional Compliance Facility Manager Regional Compliance NSPS: Subpart Ec, Subpart IIII Manager (336)578-8901 Manager (513)543-7073 (513)543-7073 Compliance Data Comments: Inspection Date 06/15/2022 Inspector's Name Davis Murphy Inspector's Signature: �� �'1 Operating Status Operating Compliance Status Violation-emissions Action Code FCE Date of Signature: 7/6/2022 TRS Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 * HAP 2020 1.01 0.2300 22.03 0.8700 0.7000 0.8200 28.81 2019 0.9800 0.2200 20.72 0.8200 0.8900 0.7800 37.27 2018 0.9400 0.2300 19.91 0.8000 0.6900 0.7500 26.58 * Highest HAP Emitted(in ounds) 1 Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 05/18/2022 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste Pending Incinerators O1/20/2022 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste Pending Incinerators 11/09/2021 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste Pending Incinerators 10/14/2021 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste Pending Incinerators 04/15/2021 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste Pending Incinerators 12/02/2020 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste Pending Incinerators 09/25/2020 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste Pending Incinerators 04/20/2020 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste 04/30/2020 Incinerators 09/11/2019 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste 09/11/2019 Incinerators 07/16/2019 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste 07/31/2019 Incinerators 05/18/2018 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste 06/04/2018 Incinerators 11/08/2017 NOV/NRE Part 60-NSPS Subpart Ec Hospital/Medical/Infectious 11/17/2017 Waste Incinerators for Which Construction is Commenced>June 20, 1996 11/08/2017 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste 11/17/2017 Incinerators Performed Stack Tests since last FCE: Date Test Results Test Method(s) Source(s)Tested 02/24/2022 Compliance Method 9 ESOI, ES02 11/17/2021 Pending Introduction On June 15,2022,Mr. Davis Murphy of the DAQ Winston-Salem Regional Office contacted Mr. Kirk Yarbrough,Facility Manager, and Don Nuss, Regional Compliance Manager,of Stericycle, Inc. for a targeted compliance inspection.This site is a hospital, medical, and infections waste incineration facility that operates two identical incinerators. Mr. Yarbrough indicated that this facility operates 24 hours per day, 7 days a week,and 52 weeks per year. This facility was previously inspected by Mr. Murphy on May 18,2021 and appeared to be in compliance with their Air Quality Permit at the time. IBEAM contact information was confirmed as correct. Mr. Murphy reviewed the coordinates for this facility in IBEAM and found that they were correct. Permitted Sources Emission Emission Source Description Control Control Device Description Source Device ID No. ID No. ES01 dual chamber hospital,medical and infectious CD07 one selective non-catalytic reduction waste incinerator(HMIWI)firing natural gas (SNCR)system with ammonia or urea (4.6 million Btu per hour primary chamber injection(19,700 ACFM, outlet burner and 6.0 million Btu per hour secondary airflow rate 2 Emission Emission Source Description Control Control Device Description Source Device ID No. ID No. chamber burner) CDO 1 one packed bed scrubber and associated quench column CD03 venturi scrubber equipped with a mist eliminator CD05 one sulfur impregnated carbon bed 6,000 ACFM, inlet airflow rate ES02 dual chamber hospital,medical and infectious CD08 one selective non-catalytic reduction waste incinerator(HMIWI)firing natural gas (SNCR)system with ammonia or urea (4.6 million Btu per hour primary chamber injection(19,700 ACFM,outlet burner and 6.0 million Btu per hour secondary airflow rate chamber burner) CD02 one packed bed scrubber and associated quench column CD04 venturi scrubber equipped with a mist eliminator CD06 one sulfur impregnated carbon bed (6,000 ACFM, inlet airflow rate) EG 1 diesel-fired emergency generator(500 N/A N/A (MACT, kilowatts maximum capacity) ZZZZ; NSPS, IIII Insignificant/Exempt Sources Emission Source ID No. Emission Source Description I-CT-I and Two cooling towers(55,200 gallons per hour water I-CT-2 recirculation rate each I-AMM Facility-wide storage of 19%aqueous ammonia Safety Inspectors visiting this site are required to wear the following PPE: Steel-toed shoes,a reflective vest, and safety glasses. Hearing protection may be needed in certain areas. There were not any additional COVID-19-related requirements,aside from usual best practices. Applicable Regulations According to Air Permit 05896T24,this facility is subject to Title 15A North Carolina Administrative Code(NCAC)2D .0516,2D .0521,2D .0524(40 CFR Part 60 Subpart IIII),2D .1100,2D .I 111 (40 CFR Part 63 Subpart ZZZZ),2D .1206,2D .1806 and 40 CFR Part 62, Subpart HHH.The facility is also subject to additional rules listed in the general permit conditions.This facility is not subject to RMP requirements of the 112(r)program since it does not use or store any of the regulated chemicals in quantities above the threshold levels in the rule. They are subject to the General Duty Clause. It is noted that aqueous ammonia is a 112(r) listed material, but only in concentrations of 20%or greater. Since this facility uses 19%aqueous ammonia,they are not subject. Discussion This facility operates two dual chamber hospital,medical,and infectious waste incinerators(HMIWI)(ESOI and ES02). Each unit is equipped with a 4.6 million Btu per hour natural gas burner for the primary chamber and 6.0 million Btu per hour natural gas burner for the secondary chamber.The control system for each incinerator consists of a selective non-catalytic reduction(SNCR)system with ammonia or urea injection(CD07&CD08), a packed bed scrubber and associated quench column(CDO 1 &CD02), a venturi scrubber equipped with a mist eliminator(CD03 &CD04),and a sulfur impregnated carbon bed(CD05 and CD06). The control 3 systems operate in series.The following description of the process for this facility was borrowed from a previous inspection report (Taylor Hartsfield,9/2/2020): A hopper is loaded with boxes of HMIW,which represents a charge.The hopper is tipped into an open pre- incineration chamber,and,after closing,a hydraulic ram pushes the charge into the primary combustion chamber. From there,the charge is combusted as it moves down the primary chamber,aided by other rams and underfire air. At the end of the primary chamber,the ash and non-combusted material is quenched with water and an auger transfers the ash to a waste bin.This bin then goes to a landfill as the waste no longer has its original hazardous properties. Back in the incinerator,the combustion gases from the primary chamber travel up to a secondary chamber.A secondary burner destroys any combustible content of the primary combustion gases and reduces CO emissions. The exhaust then enters the SNCR system where ammonia or urea is injected in order to reduce NOx formation. Afterwards,the gases enter a packed bed scrubber and associated quench column. The packed bed scrubber has a caustic solution to reduce acid gas emissions. The quencher reduces temperature which reduces dioxin/furan emissions.After quenching,the gases pass into the venturi scrubber to reduce PM emissions. Following the venturi scrubber,the gases go through a mist eliminator to remove some of the steam plume.The last step is for the exhaust to pass through the sulfur impregnated carbon bed to reduce mercury emissions. During the inspection,unit one(ESO1)was shut down for an extensive overhaul that will take many months to complete.The overhaul will include(but will not be limited to): • The rebuilding and replacement of aged components; • A new computer control system and data acquisition system(DAS); • The upgrading of many ancillary components(e.g. pumps,sensors, controllers)to improve operations; • The replacement of the unit's CO CEMs and gas conditioning system. Mr. Yarbrough and Mr.Nuss walked Mr. Murphy through the upgrades and Mr. Murphy saw some of the work in progress. Upgrades to Unit two will be completed following the re-start of Unit one. Unit two(ES02)was operating during the inspection. Boxes of HMIW are brought from trucks and sorted on the tipping floor. Any waste that cannot be processed at this facility(such as dental waste) is flagged and sent to one of the company's other sites for processing.These boxes represent a"charge"of material,which is scanned in and weighed prior to being incinerated. The units may incinerate up to 10 charges per hour,weighing up to 180 pounds each. A single charge takes about 6 minutes to pass through an incinerator. Charge rates and controls system operating parameters during the inspection are summarized in the table in the"Permit Conditions"section of this report. Mr. Murphy observed the control system and it appeared to be in good working order. Most of the controls operate under an induced draft,as a fan is located after the venturi scrubber on each unit,with an additional booster fan located after the carbon beds. Following the carbon beds,emissions are ducted to a rooftop stack for each unit. Mr. Murphy observed the stack for Unit two from the front of the facility and did not see any visible emissions,although it was noted that there was a detached steam plume on the day of the inspection. Each unit has a respective safety bypass stack located prior to the control systems, also located on the roof. The facility has a diesel-fired emergency generator(EG1)that was not in operation during the inspection.The engine is equipped with a non-resettable hours meter that read 199.1 hours during the inspection.That represents an increase of 33.4 hours since the last compliance inspection.The engine is tested weekly and is equipped with a load transfer switch,so that in the event of an emergency the engine starts automatically to avoid incinerator power loss(and possible bypass stack opening). Two exempt cooling towers(I-CT-1 and I-CT-2)provide water for the quencher,which reduces exhaust temperature. They were observed during the inspection in operation. Specific Permit Conditions/Regulations& Reporting Condition 2.1.A.1 contains the requirements for complying with 15A NCAC 02D .1100-"Control of Toxic Air Pollutants."The facility has modeled emissions limits for 12 TAPS in their permit. For the most part,the facility complies with these limits by complying with permit condition 2.1.A.2,but there are a few specific requirements under this condition, including: • The charge rate for the incinerators is limited to 1,870 pounds per hour, each. • The stack heights are limited to 82.4 feet above ground level. 4 • The facility is required to take specific measures to reduce bypass events, including: o Installing an uninterruptible power supply for the control system to limit reboot time for the programmable logic controllers. o Installing a power outage indicator as an input to the PLCs. o Programming the PLC such that the bypass stacks re-close within 5 minutes after a power failure. o Installing a low fuel indicator on the generator fuel tank o Installing a water pressure indicator to alert operators of a loss of water supply. o Assure continuous removal of ash from the primary chamber. o Reduce combustion air to the primary chamber by alternately shutting the fan off and on in 1-minute cycles to achieve a 50%air flow reduction during bypass events. The facility is also required to test for cadmium and mercury by permit condition 2.1.A.2.This condition also contains a requirement to not incinerate dental waste. During the inspection the 3-hour average charge rate of ES02 read 1715.2 pounds per hour on the data acquisition system(DAS) utilized by the facility. A photo snapshot of the DAS data from the facility are shown at the end of this report.The stacks for the units have been previously verified to be complaint with this condition and appeared to be unchanged during the inspection. Previous inspection reports have documented that the measures listed above to reduce bypass events have been implemented. Compliance with this condition is indicated. Further discussion regarding compliance with these requirements is shown below in the 2.1.A.2 discussion. Condition 2.1.A.2 contains the requirements for complying with 15A NCAC 02D.1206.The two HMIWI are subject to the following emission limits, as listed in Table I to 40 CFR Part 60, Subpart Ce: u k.= Pollutagt /6 4/`�/�i�21 Tiest kestl s ES02 .. Particulate matter 25 milligrams per dry standard cubic meter 9.97 mg/dscm 14.3 ing/dscm (PM) (mg/dscm) [0.011 (grains per dry standard cubic foot r/dsc Carbon monoxide 11 parts per million by volume(ppmv) Not Tested-Compliance demonstrated w/ CO CEMS Dioxins/furans 9.3 nanograms per dry standard cubic meter total dioxins/furans(ng/dscm) [4.1 grains per billion dry standard cubic feet Not tested (gr/109 dscf)]-or- 0.054 n dscm TE 0.024 r/109 dscfl Hydrogen chloride 6.6 ppmv .0940 ppm 1.74 ppm HCl Sulfur dioxide 9.0 ppmv SOz Not tested Nitrogen oxides 140 ppmv Ox Lead 0.036 mg/dscm 0.0152 mg/dscm 0.0167 mg/dscm (Pb) [0.016 grains per thousand dry standard cubic feet /103 dsc Cadmium 0.0092 mg/dscm <0.00140 mg/dscm <0.000737 mg/dscm Cd 0.0040 r/103 dsc Mercury 0.018 mg/dscm <0.00203 mg/dscm <0.000896 mg/dscm H 0.0079 r/103 dscfl *Limits based on 7%oxygen(dry basis) **Limits based on a three-run average with a minimum sample time of one hour per run, except for dioxins/furans which is based on a three-run average with a minimum sample time of four hours per run Emissions Limits and Parameter Monitoring Discussion The facility is also subject to 6%opacity limit. Emissions testing is required annually for opacity and every three years for PM, HCL, mercury, cadmium,and lead if compliance is indicated. If there is a violation of the PM or HCL standard,retesting is required more 5 frequently for those pollutants. For each stack test conducted,the Permittee shall track and record details for the waste being burned and the material that may be carried over into the stack test period. Stack testing was performed at this site from April 6-7,2021,and a test report was received at the DAQ-WSRO on May 6,2021. The test results(shown in the table above), indicate compliance with these limits,and the results were approved by DAQ's Stationary Source Compliance Branch on October 19,2021. Annual opacity testing was performed on February 24,2022. Test results were submitted to DAQ on March 22,2022 and deemed acceptable on April 19,2022.Compliance was demonstrated. Repeat performance testing for NOx and SO2 is not required,and compliance was demonstrated for NOx on both units during performance testing on April 29 and May 1,2015. Compliance was demonstrated for SO2 on both units during performance testing on May 17 and May 23,2013. The facility is required to establish minimum and maximum operating parameter values for the incinerators and associated control systems during initial performance testing and may conduct repeat performance testing to establish new operating parameters at any time. These parameters must be monitored and recorded during operations.These parameters,and their subsequent minimums/maximums,are shown in the table below. All parameters are required to remain within the acceptable range as measured on a 3-hour rolling average. Parameter*,** Maximum charge rate 1,870.0 pounds per hour 1,870.0 pounds per hour Maximum flue gas/carbon bed inlet temperature 168.1 OF 164.1 OF Minimum secondary chamber temperature 1,762.8°F 1,759.5 °F Minimum pressure drop across the venturi scrubber 39.0 inches of water 38.9 inches of water Minimum packed bed scrubber liquor flow rate 65.2 gallons per minute 66.7 gallons per minute Minimum packed bed scrubber liquor pH 4.10 4.1 Minimum SNCR reagent flowrate*** urea: 1.1 gallons per hour urea: 1.2 gallons per hour -or- -or- ammonia: 1.0 gallons per hour ammonia: 1.0 gallons per hour *Parameters as defined in 40 CFR 60.51c. **Each parameter is measured on a 3-hour rolling average. *** Facility current uses ammonia The facility is also required to install devices to monitor and record the following: • A device or method for measuring the use of the bypass stacks, including date,time,and duration. • A continuous temperature monitoring and recording system for temperature in the primary chamber of each affected HMIWI. • A continuous monitor for both oxygen and CO in order to determine proper operation of each HMIWI. The facility is required to continuously monitor each parameter.The incinerator charge rate must be recorded hourly and other parameters must be recorded every minute.Valid monitoring data must be obtained for 75 percent of the operating hours per day for 90 percent of the operating days per calendar quarter that the facility is combusting hospital waste and/or medical/infectious waste. Failure to maintain these parameters for a three-hour average constitutes a violation of the established operating parameter. A violation of the emissions limits occurs if any of the operating scenarios listed below occur: Operating Scenario Emissions Limit Violation • Above maximum charge rate AND PM • below minimum pressure drop across venturi scrubber • Above maximum charge rate AND CO • below minimum secondary chamber temperature • Above maximum charge rate AND • below minimum secondary chamber temperature AND Dioxin/furans • below minimum venturi scrubber liquor flow rate • above maximum charge rate AND HCI • below minimum packed bed scrubber liquor pH • above the maximum carbon bed inlet temperature AND Hg - • above maximum charge rate • Uses bypass stack PM,dioxin/furan,HCl,Pb, Cd and Hg 11 6 Operating Scenario Emissions Limit Violation • Above maximum charge rate AND • below minimum secondary temperature AND NOx • below minimum reagent flow rate The facility is required to observe the emission point of each HMIWI daily for any visible emissions above normal and record the observations in a logbook.A CO CEMS must be installed to determine compliance with the CO emissions limit and the CEMS must be operated in accordance with Appendices B and F of 40 CFR Part 60. Mr. Murphy reviewed records of visible emissions observations for this facility and found them to be acceptable. The facility records these inspections daily as part of a comprehensive maintenance checklist. Mr. Murphy reviewed the facility's continuous monitoring data and found that their monitoring/recording system appeared to be in compliance with this permit condition. The data required under this condition is voluminous in nature, so it was not feasible for Mr. Murphy to review this data in its entirety. The facility also has an interlock system that prevents charging of the units if the operating parameters are not being met.As previously mentioned, the facility has a DAS for monitoring all required operating parameters and use of the bypass stack. Mr. Murphy had Mr. Yarbrough pull up the DAS output database and show him numerous timeframes from the last year and the information appeared to be complete. Photo snapshots of the DAS data from the facility are shown at the end of this report, and compliance with the parametric limits is shown during these timeframes. According to the last semi-annual report received January 27, 2022 for ES01 there were 3.0 hours of inoperative monitor data and for ES02 there was 1.0 hour of inoperative monitor data during the previous semiannual period, meaning over 99%of operating data was valid. Mr. Murphy viewed the CO CEMS for each unit and discussed it operations with Mr. Yarbrough. During the inspection Unit 2 was reading 0.903 PPM and 7.97%Oz. Mr. Murphy also reviewed the daily calibration logs for each CEMS and the gas cylinders and found them to be acceptable. Each unit has a gas conditioner located near the ID fan above the incinerators. Compliance is demonstrated. Operational Standards and Inspection and Maintenance The facility may only incinerate waste that is defined as hospital waste or medical/infectious waste, international garbage, confidential documents generated by the healthcare industry,controlled substances captured by law enforcement agencies, non-hazardous trace chemotherapeutic waste materials,or non-hazardous pharmaceuticals. Dental waste may not be incinerated. The facility is required to perform an annual inspection of each HMIWI,and an annual inspection of each control device associated with the HMIWI. Each control device inspection must ensure proper calibration of thermocouples, sorbent feed systems,and any other monitoring equipment and generally observe that the equipment is maintained in good operating condition.Any necessary repairs found during the inspections must be completed within 10 days unless an extension is granted by DAQ. Specific requirements apply to the carbon beds, including: • Operating two beds in series,with the second bed serving as a guard. • Replacing each carbon bed or the carbon in the bed before it has reached the end of its useful life. • Using the same type of activated carbon used during the most recent performance test that demonstrated compliance with the Hg emission limit,until a subsequent performance test is conducted. A different type of carbon may be substituted,as long as the replacement has equivalent properties compared to the carbon used in the most recent Hg performance test. • Monitoring of the carbon beds shall be conducted consistent with the manufacturer's specifications and recommendations. • Records of performance monitoring and monitoring procedures must be maintained. The facility is required to develop and submit a waste management plant to DAQ by January 30`h of each calendar year and must implement the waste management plan in its entirety. The waste management plan must address the management of dental waste. Each HMIWI may not operate unless a trained and qualified operator is accessible at the facility or within one hour of the facility. Operators must be trained by completing the requirements of 40 CFR 60.53c(c)through(g). The facility is required to conduct an annual review of the requirements of 40 CFR 60.53c(h)(1)through(h)(10)with each operator. 7 As discussed above, the facility has a procedure in place to scan/log all incoming waste and ensure that only acceptable waste is processed. Dental waste contains a gray label and is coded in the system to be sent to an autoclave for processing. According to Mr. Yarbrough, dental waste is not supposed to be shipped to the facility but if it is inadvertently sent the computer system should flag it so it will not be incinerated. Mr. Murphy reviewed the 1&M records for the facility. PMs on Unit 2 and its associated controls were performed on February 22, 2022. The last inspection/PMs on Unit 1 were on January 18, 2021. A separate 2022 inspection was not performed since Unit I was taken down for upgrades on March 7, 2022. The carbon bed manufacturer recommends replacement of the carbon every 2-3 years. The facility inspects the carbon beds quarterly. The Carbon in Bed 1 was last changed on April 5, 2021 and the carbon in bed 2 was last changed on September 28, 2020. The facility washes the carbon quarterly or if the pressure drop exceeds 5"w.c, whichever occurs first. The pressure drop is recorded twice daily on a logsheet. Both beds used pelletized sulfur- impregnated carbon. Bed I uses Calgon Carbon and Bed 2 uses Jacobi Carbon. Honeywell performs calibrations of the monitoring equipment quarterly. Mr. Murphy reviewed the calibrations and they appeared to be adequate, with the most recent calibrations occurring for Unit 2 on April 26, 2022. The facility maintains a waste management plan and submitted it as required to DAQ-WSRO on January 27, 2022. The plan was last revised on November 11, 2005, and Pages 3-5 of the plan specifically address the management of dental waste. The facility currently has 13 operators on staff Refresher trainings were performed on November 8 and November 16, 2022. Mr. Murphy reviewed the training records and found them to be acceptable. Mr. Yarbrough indicated that the training is typically an 8-hour refresher. Recordke eking/Reporting The facility is required to maintain records of the following for a minimum of five years: • All CEMS and monitoring parameter data listed above,on the prescribed frequency in the permit. • Pressure drop across the venturi scrubber and temperature at the wet scrubber outlet(carbon bed inlet)during each minute of operation. • Records of all inspection,maintenance,and repair activities for HMIWI and control device. • Identification of days and times for which emission rates or operating parameters were not maintained or exceeded the applicable limits,the reason for such instances,and a description of corrective actions taken. • The results of any performance tests and a description of how operating parameters are re-established. • Records of HMIWI operator training. • Calibration records. • Visible emissions monitoring records. A semiannual report is required and must include the highest maximum and lowest minimum operating parameters recorded for each operating parameter for the previous calendar year.The report also must include dates where monitoring data was not collected,or exceedances were indicated. As previously discussed, all records were reviewed, and the facility appears to be maintaining the required records. The required semiannual report was received on January 27, 2022, 2021 and it contained all the necessary elements. The facility appears to be in compliance. Condition 2.2.A.I references 15A NCAC 02D .1806,which requires that the facility prevent odorous emissions from causing or contributing to objectionable odors beyond the facility's boundary. Mr. Murphy did not note any objectionable odors beyond the property boundary during this inspection.A review of DAQ records did not find any odor complaints pertaining to this facility. Compliance is demonstrated. General Conditions General Condition 3.X requires this facility to submit an emissions inventory by June 30 of each year. The CY 2021 inventory was submitted on June 15,2022,and the signed certification page submitted to Mr. Murphy during the inspection.The inventory is currently being reviewed;compliance is demonstrated. General Condition 3.MM lists the 2D .0540 fugitive dust requirements.This rule states that the facility shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. Mr. Murphy did not note any fugitive dust emissions during this inspection. It seems reasonable to expect compliance. 8 NSPS/NESHAP This facility is subject to the following NSPS and NESHAP regulations: NSPS:Subpart IIII This rule applies to the emergency generator.The requirements for the engine under this rule are summarized as follows: • The engine must comply with the emission standards 40 CFR 60.4202 and the facility must comply by purchasing an engine certified to these emission standards for the same model year and maximum engine power.The facility also must operate and maintain the engine according to the manufacturer's emission related-written instructions over the entire life of the engine. • The engine must burn ULSD. • The engine must be equipped with a non-resettable hour meter. • The engine is limited to 100 hours of operation per year for maintenance checks and readiness testing and up to 50 hours per year for certain types of non-emergency use,which is counted as part of the 100 hours per year for maintenance and testing. Usage during emergency situations is unlimited. • The facility must perform I&M on the engine as recommended by the manufacturer and maintain the results of all I&M in a logbook. As discussed above,the engine is equipped with a non-resettable hours meter that read 199.1 hours during the inspection.That represents an increase of 33.4 hours since the last compliance inspection. Mr. Yarborough provided Mr. Murphy with maintenance records for the engine.The engine was serviced on April 14,2022 by Gregory Poole Power systems.Previous DAQ compliance inspections have documented that this engine is certified. The engine burns 15 PPM ULSD,as required. Compliance is indicated. NESHAP:Subpart ZZZZ. This rule applies to the emergency generator. Compliance with this rule is demonstrated by complying with 40 CFR Part 60 Subpart II1I and no further requirements apply. Facility Wide Emissions The following table summarizes the facility wide actual emissions. The actual emissions are from the CY2019 and CY2020 emissions inventories that were submitted by the facility. Differences in CY2019 and CY 2020 emissions are due to the decreased natural gas usage and a throughput increase in unit two. The CY2021 emissions inventory is still under review at the time of this report. Pollutant CY2020 Actual Emissions, CY2019 Actual Emissions, Net Change(%) tons/year tons/year PM 1.01 0.98 3.1 PM10 0.82 0.78 5.1 PMz.s 0.56 0.54 3.7 _._ SOZ 0.23 0.22 F 4.5 NOx 22.03 20.72 6.3 CO 0.7 0.89 -21.3 VOC 0.87 0.82 6.1 HAPTota1 0.035 0.036 -3 �HAPHighest 0.014(hexane,n-) 0.019(hexane-n) -22.7 Permit Issues Condition 2.1.A.2.c incorrectly states that Method 29 shall be used for sampling chromium (VI). Instead, SW 846 Method 0061 shall be used for chromium(VI). There appears to be an inconsistency between the parameters listed in condition 2.1.A.2.d and the table shown in condition 2.1.A.2.n.One section requires the permittee to monitor the liquor flow across the venturi scrubber while the other requires the permittee to monitor the liquor flow across the packed bed scrubber.This inconsistency continues in the table under condition 2.1.A.2.o as well. 9 Previous Source Tests The most recent source tests for this facility are summarized below: On February 24,2022,the facility performed Method 9 testing of both in incinerators for visible emissions. The visible emissions limit as established in 15A NCAC 2D .1206"Hospital,Medical and Infectious Waste Incinerators"and 40 CFR Part 62 Subpart HHH"Federal Plan Requirements for Hospital/Medical/Infectious Incinerators Constructed on or Before June 20, 1996" is 6%for a rolling 6-minute block average. For both incinerators,the maximum observed opacity was 0%and the average opacity was 0%. The results were received on time and indicated compliance with the applicable limit,as indicated in the DAQ-WSRO memo on April 19,2022. On April 6-7,2021,the facility performed testing on both units. Both HMIWI were tested for particulate,visible emissions (VE),hydrogen chloride(HC1)and metals(lead,cadmium, and mercury)using EPA Methods 5,9,26A,and 29. Results, which were approved by DAQ's Stationary Source Compliance Branch on October 19,2021,are shown in the specific permit conditions section of this report and indicated compliance. On April 8,2020,the facility performed Method 9 testing of both incinerators for visible emissions. The visible emissions limit as established in 15A NCAC 2D .1206"Hospital, Medical and Infectious Waste Incinerators,"and 40 CFR Part 62 Subpart HHH"Federal Plan Requirements for Hospital/Medical/Infectious Incinerators Constructed on or Before June 20, 1996" is 6%for a rolling 6-minute block average. For both incinerators,the maximum observed opacity was 0%and the average opacity was 0%. The results were received on time and indicated compliance with the applicable limit,as indicated in the DAQ-WSRO memo on May 12,2020. Compliance History(Last Five Years) May 18,2022-The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)due to the facility experiencing an event on April 28,2022,with a duration of one hour and two minutes during which the control system for ES02 was bypassed. The cause of the bypass was attributed to a loss of cooling water flow,which resulted in high absorber temperatures.The bypass stack event was a violation of 2D .1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25.A response was not received. This enforcement case has not yet been submitted as of the date of this report. January 20,2022-The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)due to the facility experiencing an event on December 31,2021,with a duration of six minutes during which the control system for ESO 1 was bypassed twice.The cause of the bypass was a result of an electrical short in wiring in the conduit next to the feed hopper,causing a tripped Programable Logic Controller(PLC),causing the bypass tack to open for three minutes. Following initial investigation, personnel attempted to reset the braker,which tripped again and caused the bypass stack to open for an additional three minutes. These bypass stack events were violations of 2D .1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25. A response was not received. This enforcement case has not yet been submitted as of the date of this report. November 9,2021-The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)due to the facility experiencing an event on October 15,2021,with a duration of twelve minutes during which the control system for ESO I was bypassed. The cause of the bypass was an absorber pump motor failure,with the resulting loss of flow leading to high absorber temperatures and subsequent opening of the bypass stack. This bypass stack event was a violation of 2D .1206 as referenced by Condition 2.I.A.2.o of Air Quality Permit 05896T25. A response was not received. This enforcement case has not yet been submitted as of the date of this report. October 14,2021-The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)due to the facility experiencing an event on September 15,2021,with a duration of three minutes during which the control system for ES02 was bypassed. The cause of the bypass was a result of the lead incinerator operator mistakenly shutting off the scrubber on this incinerator, resulting in the opening of the bypass stack for three minutes. This bypass stack event was a violation of 2D .1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25. A response was not received. This enforcement case has not yet been submitted as of the date of this report. April 15,2021 -The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)due to the facility experiencing an event on February 1,2021,with a duration of two minutes during which the control system for ESO1 was bypassed. The cause of the bypass was a result of a faulty feed hopper limit switch,which resulted in a programmable logic controller (PLC)fault. At the time of the event,personnel immediately cleared the fault,restarted the air pollution control(APC)system to close 10 the bypass stack,and placed Unit 1 in shut down.After the shutdown was completed,the facility investigated, identified,and replaced a faulty feed hopper limit switch and input card within the PLC.The facility experienced another event on February 3,2021,with a duration of two minutes during which the control system for ES02 was bypassed. The cause of the bypass was a result of a broken conduit joint which was attributed to excessive hydraulic line vibration.The broken conduit joint led to an electrical short,which caused a PLC card to fault,resulting in the bypass stack opening.The faulty conduit was replaced and rerouted to avoid vibration.The bypass stack events were violations of 2D .1206 as referenced by Condition 2.l.A.2.o of Air Quality Permit 05896T25.A response was not received.This enforcement case has not yet been submitted as of the date of this report. December 2,2020—The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)due to the facility experiencing an event on October 22,2020,with a duration of three minutes during which the control system for ESO 1 was bypassed.The bypass was caused by a fault in the programmable logic controller(PLC)which resulted in a control power loss.At the time of the event,personnel immediately cleared the fault,restarted the air pollution control(APC)system to close the bypass stack, and placed Unit 1 in shut down.After the shutdown was completed,the facility investigated, identified,and replaced a faulty I/O card within the PLC.The facility experienced another event on November 13,2020,with a duration of three minutes during which the control system for ES02 was bypassed.The bypass was caused by a faulty level controller in the cooling tower which caused high temperature in the absorber. Immediately upon detection,facility personnel restarted the APC system to close the bypass stack and placed Unit 2 in shut down.After the shutdown was completed,the facility investigated and identified the faulty level controller and replaced it.The bypass stack events were violations of 2D .1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25.A response was not received.This enforcement case has not yet been submitted as of the date of this report. April 20,2020—The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE) due to the facility experiencing an event on January 31,2020,with a duration of three minutes during which the control system for ESO1 was bypassed.The cause of the bypass was a result of a relay on the ash system shorting out,which caused the circuit breaker to trip off. Once the circuit breaker tripped off,the ID fan stopped operating,causing the short duration bypass.The circuit breaker was reset immediately which restarted the fan.The facility experienced another event on March 29,2020,with a duration of twelve minutes during which the control system for ES02 was bypassed.The cause of the bypass was a result of a faulty draft transmitter.The faulty transmitter registered a positive draft when, in fact,the system was shutting down normally.This false positive resulted in the stack cap opening.The scrubber system and ID fan continued to run normally,but the bypass stack was open. The bypass stack events were violations of 2D .1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25.A written response letter was received by the WSRO on April 30,2020. The enforcement case No. 2020-042 has not yet been assessed. September 11,2019—The facility received a Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE)due to the facility experiencing an event on August 13,2019,with a duration of thirteen minutes during which the control system for ES02 was bypassed.The event was the result of a breach in the piping in the packed bed scrubber (Control Source ID No. CD02). The breach resulted in a sudden loss of water flow, causing temperatures in the scrubber to rise to an unsafe level.Use of the bypass stack was necessary to prevent a catastrophic failure of other components in the scrubber system that cannot tolerate extremely high temperatures.The bypass stack event was a violation of 2D .1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25.The written response letter received by the WSRO on July 29,2019,for the July 16,2020 NOV/NRE(see below)was also applied to this violation. Per enforcement case No. 2019-079,the facility was assessed a civil penalty of$10,308. July 16,2019—The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)due to the facility experiencing an event on April 22,2019,with a duration of eleven minutes during which the control system for ESO 1 was bypassed. The event was the result of a short in the light located on top of the ash hoe electrical panel,which caused a blown fuse in the main control panel for the stack cap.The blown fuse activated an uninterruptable power supply (UPS)system,which continued to deliver power to the control panel as designed. When the batteries in the UPS system were exhausted,the control systems failed,and the bypass stack cap was opened. The bypass stack event was a violation of 2D .1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25. A written response letter was received by the WSRO on July 29,2019. Per enforcement case No.2019-079,the facility was assessed a civil penalty of$10,308. February 19,2019—The facility received a Notice of Deficiency(NOD)due to the facility failing to perform HMIWI operator training in CY2018.This was a deficiency of 2D .1206 as referenced in Condition 2.1.A.2.ee of Air Quality Permit 05896/T25.A response was received on May 6,2019 and indicated that the training was done on January 28-30,2019. The training will be performed in the first quarter,rather than the fourth quarter,of each year going forward. 11 May 18,2018—The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOWNRE) due to the facility experiencing an event on April 15,2018,with a duration of eight hours during which the control system for ESO 1 was bypassed. The event was the result of a programable logic controller(PLC) fault indicating an invalid rack configuration error code failure,thus removing control power to the HMIWI.The bypass stack event was a violation of 2D .1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25. A written response letter was received by the WSRO on June 4,2018. Per enforcement case No.2018-025,the facility was assessed a civil penalty of$5,256,which was paid in full on September 6,2018. November 8,2017—The facility received a NOV/NRE due to the facility experiencing four discrete events on September 10, 22,26, and October 7,2017,with durations of 14, 10,2,and 3 minutes, respectively, during which the control system for one of the HMIWIs was bypassed.The first and fourth event involved ES02,and the second and third events involved ESO1.The first three events were the result of failures of the uninterruptible power supply(UPS)unit,thus removing control power to the HMIWI.The last event was the result of frayed wires causing a short,thus removing control power to the HMIWI.The bypass stack events were violations of 2D .1206 as referenced by Condition 2.I.A.2.o of Air Quality Permit 05896T25.A written response letter was received by the WSRO on November 21,2017. Per enforcement case No.2017-066,the facility was assessed a civil penalty of$20,249,which was paid in full on May 2,2018. Conclusion Based review of records and visual observations,this facility appeared to be in compliance at the time of the inspection. 12 ES02-Data Acquisition System snapshot X Data Clock t ------ - DAS: ![<sw Rivet,Number 1 6' 5 ?1137:44 AM � SNIIF'SHQT; MIN AVG 3 HCi AVG* LIMIT 1 1.0751719': 1-86769' 14Y Verson 1.00.19 69� 7.97 r99776671 h1A Stack Cap Position CLOSED i F' s.Temp.deyF I E 1977246� D!?1 t2p�ratiortal Status q1-NORMAL^ � or>ckary Temp .tieyF 1931 1930.7 1928116E t°01 Trend Chart rietec:tiOns S,N(-R Reagent How-9Rh �128 1 232 Cl 223495� 6.sec 1 tlur :#Hr `'rend r r'i r Absorber PH 6,71 GMZI [ ye,tu; OP N ri.G_ 5}[ 42�f442261277 O Screen Selections [�Verdtm Rec�rc.c tm 1 - 74�- 741[ ._99%4 Caiibra#on inPth l.mG5 Sena(Fo[rn rlamis [) f[?Fan hdd Tert t de4H --- 36I 136 135.94944 �705.4 CJ Carbon 1' 4 TeMp afe9F 161 161 -16Q Charm Rate" __- 77054 ---�121 �.._-17I52 ❑l3ecord Mnute Data " CO 12 HA AVG 02=1 NR AVG �•Charge Raw-Curtent tiR,Last HR,3 t1R AVG 13